Summary of Ryan v. N. Y. Central R. R. Co., Ct. of App. N. Y. 1866
Relevant Facts: The N Y Cen R Co, by the negligent manner of conducting an engine, or by the defective condition of the engine, set fire to a quantity of wood in one of their sheds. The fire consumed the woodshed, and spread to and consumed the house of the plaintiff, situate about one hundred and thirty feet distant from the shed. A number of other houses were also burned by the spreading of the fire.
Legal Issue(s): Whether when a house in a city takes fire, through the negligence of the owner or his servant; the flames extend to and destroy an adjacent building: Is the owner of the first building liable to the second owner for the damage sustained by such burning?
Court’s Holding: No
Procedure: The judge at the Circuit nonsuited the plaintiff, then fifth district affirmed. Affirmed.
Law or Rule(s): Every person is liable for the consequences of his own acts. He is thus liable in damages for the proximate results of his own acts, but not for remote damages.
Court Rationale: The result of this firing of the Pl’s building depends upon a concurrence of accidental circumstances, such as the degree of the heat, the state of the atmosphere, the condition and materials of the adjoining structures and the direction of the wind. These are accidental and varying circumstances. The party has no control over them, and is not responsible for their effects. The reason that the damages incurred are not the immediate but the remote result of the negligence of the defendants. The immediate result was the destruction of their own wood and sheds; beyond that, it was remote. The negligent burning of a house, and the spreading of the fire to a neighboring house, and the burning thereof, do not give the owner of the last house a cause of action against the owner of the house in which the fire originated. The damages are too remote.
Plaintiff’s Argument: Df’s negligent actions directly caused the destruction of pl’s building.
Defendant’s Argument: The reason that the damages incurred are not the immediate cause of the df’s negligence but the remote result of the negligence of the defendants.